While the Sarbanes-Oxley Act of 2002 has traditionally protected employees from retaliation for “blowing the whistle” on improper conduct by their employers, a recent decision by the U.S. District Court for the Southern District of New York extends that protection to employees who report putative wrongdoing by clients or customers of their employers. This update examines the ruling and its implications for the newly enacted whistleblower provisions under Dodd-Frank, which provide substantial monetary incentives for whistleblowers.